Real-estate AML under AMLR: sales, lettings and developers

Real-estate AML work should follow the transaction, not just one client record. When a sale or qualifying letting is in scope, the office has to understand both sides, the property, the payment route and the timing of verification.

The key operational point is timing: the file should move from lead to accepted offer, then through a CDD gate before funds or property transfer. That gate is where buyer/seller or landlord/tenant checks, UBO evidence, sanctions, cash controls and reliance evidence come together.

Property developers need special care. Selling own stock or off-plan units is not the same as acting as an estate intermediary, but developers still need a clean evidence hand-off for notaries, banks, sanctions, GDPR and cash-control questions.

Who this applies to

Estate agents, in-scope letting intermediaries, notaries and offices supporting property transactions need a file that proves when the AMLR gate was reached and what was checked. Developers need a different, honest track when they are selling their own stock rather than intermediating for third parties.

• Buyer and seller in property sales
• Landlord and tenant for qualifying lettings
• Company parties, representatives and beneficial owners
• Developers with brokerage, intermediation arms or suspicion triggers

Legal and supervisory context

AMLR treats real-estate intermediation as an obliged-entity activity and makes both parties customers when the transaction is in scope. It also separates timing: verification can happen after an offer is accepted, but before funds or property are transferred.

For lettings, the EUR 10,000 threshold is a monthly rent threshold. Deposit, advance rent, charges or annualised value may matter for risk understanding, but they should not be used as a substitute threshold test.

What the office must actually do

The office should record why the file is in scope or evidence-only, collect CDD for every required side, verify legal entities and UBOs, check sanctions and PEP/adverse signals, review source-of-funds concerns and block transfer if the gate is not clear.

• Record offer accepted before opening the transfer gate.
• Run separate party status for each required role.
• Capture LEI where available and representatives acting on behalf of a party.
• Document any reliance on another obliged entity with evidence and approval.
• If CDD cannot be completed, refrain or terminate and consider whether STR escalation is needed without tipping off.

What good evidence looks like

Good evidence shows the deal type, property, rent calculation, parties, accepted-offer date, CDD status, cash-control result, reliance scope, gate blockers and final transfer/closing decision. It should be boring, dated and easy to inspect.

Common mistakes supervisors find

• Treating a property deal as a one-sided client file.
• Using deposit or annual value to force a letting over the EUR 10,000 monthly rent threshold.
• Letting funds or property transfer before both required sides are complete.
• Relying on another obliged entity without evidence, scope and approval.
• Marketing developer own-stock files as automatically AMLR intermediation.

Practical checklist

• Classify sale, letting or developer support file.
• Record monthly rent and excluded amounts separately.
• Record accepted-offer date before the transfer gate.
• Complete buyer/seller or landlord/tenant CDD.
• Verify legal entities, UBOs, LEI and representatives where relevant.
• Attach reliance evidence and approval where used.
• Block transfer on cash, CDD failure or unapproved reliance.

FAQ

Official references

• EUR-Lex — Regulation (EU) 2024/1624
• EUR-Lex — AML package summary and application dates